What was hallucinated

Fabricated: Case Law | AI-generated, non-existent/incorrect Westlaw citation for Three Arrows Capital appearing in the Motion; corrected in Schedule A. || Misrepresented: Case Law | Garbled/doubled citation for Soundview Elite (mixed volumes, pages, and years) in the Motion; corrected in Schedule A. || False Quotes: Case Law | Inaccurate quotation/misstatement attributed to Soundview Elite in the Motion (garbled language and tense); corrected in Schedule A. || Fabricated: Case Law | Clearly erroneous citation with impossible year/number formatting for Three Arrows/related filings (e.g., year '20234'); corrected in Schedule A.

Details

Sullivan & Cromwell acknowledged that its April 9, 2026 Motion contained AI-generated inaccuracies including fabricated and misquoted case citations. The firm apologized, identified and corrected the errors in Schedule A, undertook remedial measures, and filed corrected papers. The issue was brought to the firm's attention by opposing counsel (Boies Schiller Flexner).

Sanction teardown · S.D. New York (Bankruptcy), USA · 2026-04-18

In re Prince Global Holdings Limited, et al.

What happened

In S.D. New York (Bankruptcy), USA, a filing relied on an unnamed/unconfirmed AI tool to help draft legal argument. The court identified the following problems with the citations in that filing:

Fabricated (Case Law)

AI-generated, non-existent/incorrect Westlaw citation for Three Arrows Capital appearing in the Motion; corrected in Schedule A.
Misrepresented (Case Law)

Garbled/doubled citation for Soundview Elite (mixed volumes, pages, and years) in the Motion; corrected in Schedule A.
False Quotes (Case Law)

Inaccurate quotation/misstatement attributed to Soundview Elite in the Motion (garbled language and tense); corrected in Schedule A.
Fabricated (Case Law)

Clearly erroneous citation with impossible year/number formatting for Three Arrows/related filings (e.g., year '20234'); corrected in Schedule A.

Which AI tool

an unnamed/unconfirmed AI tool. Note: Charlotin's public database records tool attribution only where a court order, brief, or reporting on the matter states it explicitly; "unidentified" or "implied" means the record indicates AI use but does not name a specific product — we do not guess.

Outcome

Firm apologised

Additional detail

How Citation Safe would have caught this

Citation Safe runs three deterministic layers before a brief is filed: (1) does the citation exist against CourtListener's database of published opinions, (2) if quoted, does that exact language appear in the source, (3) does the cited case actually support the proposition it is cited for. Fabricated case citations fail Layer 1. Fabricated or misattributed quotations fail Layer 2 even when the underlying case is real. Misrepresented holdings — a real case cited for a proposition it does not support — are the target of Layer 3. None of these checks involve asking another language model whether the citation looks right; they are lookups and text-matches against the actual source, which is why a hallucinated citation has to survive a direct lookup against the authoritative source — not another model's opinion — to earn a VERIFIED stamp; our measured false-verify rate is published live at /quality.

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Source: https://www.damiencharlotin.com/documents/2002/In_re_Prince_USA_18_April_2026.pdf, via Damien Charlotin's public AI Hallucination Cases Database (CC0).

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